ML20054J153

Expresses Concern That Facilities Are Not Being Constructed W/Safety Design Features Warranted as Result of Reactor Operating Experience & Increased Knowledge of Unresolved Safety Issues

ML20054J153
Person / Time
Site:	Marble Hill
Issue date:	06/21/1982
From:	Frey D SASSAFRAS AUDUBON SOCIETY
To:	Youngblood B, Youngblood B Office of Nuclear Reactor Regulation
References
NUDOCS 8206280210
Download: ML20054J153 (5)

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B. F. Youngblood, Chief -

Licensing Branch No.1, DL Nuclear Rogulatory Commission Washington, D.C. 20555

Dear Mr. Youngblood:

Sassafras Audubon is concerned as to whether Marble Hill Units 1 and 2 am being constructed with safety design featums warranted as the result of reactor operat-ing experience and inemased knowledge of unresolved safety issues (USI). Our concern is related to many USI both scognized or nominated by the NBC staff and Advisory Committee on Reactor Safeguards, although only a few am addmssed in this letter.

Pmasurized Water Reactor Steam Generator Tube Integrity Puhlic Service Indiana (PSI) mentioned in its 15T/8 Annual Report that 4 Uosting-houso steam generators vom on site. We assume that these generators am simi'Inr to the models that have been subject to chronic wastage and denting in operating pmasurized water mactors (PWR's). Is this so? Will PSI be permitted to install these generators in Marble Hill Units 1 and 2, or will they be required to install a model with guarunteed maistance to such degradation?

Thermal Shock / Embrittlement Radiation "embrittlemnt" of reactor pressure vessels, particularly those of PWR's, is occurring more rapidly than expected. This is likely to mduce the capacity and life-oxpectancy of PWR's and make their pressure vessels susceptible to rupture and loss-of-coolant accidents. Will the mactor vessels at Marble Hill be composed of materials similar to those used in the present generation of nuclear plants, or will the reactor vessels be composed of materials insensitive to neutron bombard-mont of tho vessel walls? Or will design modifications be made to lessen neutron radiation by other means? During construction?

Soismic Desinn Criteria Only mcently the United States Geological Survey (USGS) has identified the deep fracturn that caused the New Madrid earthquakes of 1811 and 1812, the om of Feb-ruary 7,1812, being the strongest earthquake in recorded history of the United States. The USGS found a " rift where the earth is- literally tearing apart", some 55 miles long in a northeast direction and with shifts of 3000 feet in the rock 8206280210 B20621 Apph PDR ADDcK 05000546 L A PDR

_2-formation mom than a mile underground.

Seismologists have warned the public that the New Madrid rift mpmsents a high risk earthquake ama whom another major quake is overdue. They also class the lower Ohio River Valley, including the City of Evansville, as a zone of poten-tially heavy earthquake damage. Southern Tnaiana had a moderate earthquake 'near Vincennes in 1909g and has been shaken by thme in mcont years, 1968 (5 5 Richter),

lW4 (4 7 Richter), and 1980(5.1 Richter) . Vincennes, Marble Hill, and Maysville, Kentucky, the latter at the epicenter of the 1980 earthquake, are on approximately the same parallel.

In its Marble Hill Safety Evaluation Report (lW7), the NRC noted that earthquakes considend to be significant in the seismic design of Marble Hill am VII-VIII Modified Merealli intensity near the site, and II-XII Modified Merea31i intensity about 110 miles from the site, pending the outcome of ongoing macarch programs to detemine the geologic, seismic, and tectonic characteristics of the Wabash Valley and the New Madrid Amas. The NRC concluded (page 2-26):

" Based on our myiew we conclude that the occurmnce at the site of a Modified Mercalli intensity VI is. a low probability event. There-fom, we concur with the applicants that eight per cent of the ac-celeration of gravity is an acceptable acceleration level for the operating basis earthquake, mpmsonting an earthquake which could masonab3,y be expected to affect the plant site during the operating life of the plant."

What am the maults of the maearch program? Am NRC seismologists in agreement?

What am the implications for Marble Hill? Has the IEEE Standards Committee m-sponsible for seismic quaWication guidance afined their curmnt criteria for safety-mlated equipment? Does the NRC staff forsee avisions: of mquimments for Marble Hill in terms of support stmetums of steam generators, mactor cool-ant pumps, the pmssurizer, and the mactor vessels?

Degradation of Thwaded Fasteners in the Reactor Coolant Pmssum Boundary A significant number of incidents of degradation of thmaded fasteners in the m-actor coolant pmssum boundary have been mported in the last several years. Ex-tensive failum of thmaded fastemrs, combined with failum of detection, could usult in a serious loss-of-coolant accident. Could not seismic shock waves weak-en and contribute to failum of degraded studs?

Can the root cause of primary coolant Jaakage in this instance be effectively con-trolled? Will the NRC mcommend and/or mquim studs mom maistant to a corrosive envimnment and to stmas-corrosion cracking? Can measums be taken during the constmetion of Marble Hill to prevent or lessen the possible occurance of this-problem?

Marble Hill as a Iong-Tem. High-level. Radioactive Waste Storane Site When PSI was granted a construction pemit for Marble Hill, only a minimal amount of spent fuel, a total of one and two-third coms, approximately 340 spent fuel assemblies, was to be stomd on site for any length of time. Now, it seems likely that all the spent fuel from Marble Hill will be stomd on site, indefinitely.

A permanent, licensed government facility (or facilities) for the disposal of

commrcial high-level radioactive wastes, for both spent fuel and the " activated" hulks which surrounded the coms, keeps meeding into the distance. Away-Fmm-Reactor (AFR) storage facilities are being opposed on a number of grounds, but if they become reality, are likely to be preempted for spent fuel from the plants currently operating.

The storage of Marble Hill's spent fuel on site, both during and after Marble Hill's operational phase, and the "mothballing d or " entombment" of the Marble Hill plants in situ, greatly enhances and prolongs the risks associated with nuclear accidents and major seismic events.

How will spent fuel be stored at Marble Hill? Will the foundation excavation for the spent fuel storage facility be extended to the same quality rock foundation as the reactor containment buW4ng? What will be the Seismic Category of construc-tion? The Ibw Madrid earthquake is supposed to have been around 6 on the Richter scale in magnitude of effect in the Marble Hill Area. Will Marble Hill be designed to withstand such a quake?

Environmntal Qualification of Safety-Related Electrical Eauipment Public Service Indiana proposes, at present, to file an updated FSAR to the NRC in December 1982 to support a fuel load date for Unit 1 of June 1986. This schedule would appear to provide PSI ample time with which to comply with NRC criteria for environmental qualification of safety-related equipment prior to Hearings on an operating license for Marble Hill. Is this not so?

Sassafras Audubon agrees with former NBC Commissioner Bradford and Commissioner Gilinsky that specific seismic and dynamic criteria for qualif'ication of electric equipment shou 14have been included in the recent rule. Will seismic and dynamic qualificatiofi[d6r#dfectric equipment be formulated by the ITRC in time to be in-corporated into the construction of Marble Hill?

Marbin Hill a Replicate of Byron?

The Byron Nuclear Plant of Commonwealth Edison was the subject in 1980 of an audit of structural calculations for selected structures, and of an independent struc-tural analysis of the containmnt structure and one other safety-related structum, to determine whether it was, in fact, being built to withstand natural phenomena and potential accidents, such as that of TMI-2.

Marble Hill is a sister plant of Byron and we would like to know the results of the study by E G and G Idaho Inc. Is the Report, or summary of the Report, avail-able to the public?

PSI has asked that the NRC staff make optimum use of the replicate design of Byron in its review of Marble Hill. How far advanced is Byron in the construction-licens-ing process? How closely can Marble Hill replicate Byron? Does Byron have a seismic problem on the scale of Marble Hill?

PSI recently requested an exemption from 10CFR 50 34(g), a rule which requires applicants to evaluate differences from the standard review plan. What were the differences in question? Wre they in any way related to the Byron design?

A Petition for Investigation was filed by tle Consu:aer Counselor of Itx11ana with tb Indiana Public Servico Cortission on April 28, 1922 requesting an investigation of Public Service I.ndiana's construction program, including its Marble Hin Pmject, and in particular an investigation of tle effect of such a program on pasent and futum rates. The Petition was granted and a liearing on the cause will be held on October 14, 1982 in tie Jeffersomh/New Albany ama, as part of a series of llearings on a PSI petition for approval of new rates for electric service.

Tim matters raiced in this letter am an integral part of the pmsent investigation of Marble 11111 because they are concerned with its cost, as it will be aflected in pmoent and future customer rates.

The infomation is reeded now so that citirons may know whether safety-zelated modi-fications are being built-into tle plants during construction, or postponed until crices develop as the result of accidents and/or degradation of equipment.. Back-fitting, replacecent of equiptent, and repair of equipment, is more costly and dir-ficult in a radioactive envirore:ent.

Yours sincerely,

?nw c6IdkQy Mrs. Ihvid G. Frey ErerEy Policy Committee, SAS 2625 S. Smith Road Bloomington, Indiana 47401 cc : D. Einerlnit L. Parvin Prico -

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